State v. Ruggles

2024 Ohio 3128
CourtOhio Court of Appeals
DecidedAugust 16, 2024
Docket2024-CA-2
StatusPublished

This text of 2024 Ohio 3128 (State v. Ruggles) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Ruggles, 2024 Ohio 3128 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Ruggles, 2024-Ohio-3128.]

IN THE COURT OF APPEALS OF OHIO SECOND APPELLATE DISTRICT GREENE COUNTY

STATE OF OHIO : : Appellee : C.A. No. 2024-CA-2 : v. : Trial Court Case No. 2023-E-00004- : 01,02,03,04,05 LATRICIA RUGGLES : : (Appeal from Common Pleas Court- Appellant : Juvenile Division) :

...........

OPINION

Rendered on August 16, 2024

MAXWELL D. NEWSOME, Attorney for Appellant

MEGAN A. HAMMOND, Attorney for Appellee

.............

WELBAUM, J.

{¶ 1} Appellant Latricia Ruggles appeals from her convictions in the Greene

County Court of Common Pleas, Juvenile Division, after a jury found her guilty of five

counts of contributing to the unruliness of a child in violation of R.C. 2919.24(B)(2). In

support of her appeal, Ruggles contends that the complaint charging her with those -2-

counts was defective because it failed to set forth all the essential elements of the charged

offense as required by Crim.R. 3. Ruggles claims that such a defect warranted the

dismissal of the complaint and that this court should reverse her convictions on that basis.

Ruggles also claims that her convictions should be reversed because they were not

supported by sufficient evidence and were against the manifest weight of the evidence.

Ruggles further claims that a reversal is warranted because the trial court committed

prejudicial error by prohibiting the admission of certain testimony about Ruggles’s niece

on grounds that such testimony was irrelevant. For the reasons outlined below, the

judgment of the trial court will be affirmed.

Facts and Course of Proceedings

{¶ 2} On August 10, 2023, the State, through the attendance officer of Fairborn

City Schools, filed a complaint charging Ruggles with five first-degree-misdemeanor

counts of contributing to the unruliness of a child in violation of R.C. 2919.24(B)(2). The

complaint alleged that Ruggles had acted in a way tending to cause her teenage Daughter

(“Daughter”) to become an unruly child during five periods of time between September

2022 and May 2023. Under each of the five counts, the complaint alleged that Ruggles

had failed to ensure that Daughter attended the public school at which she was enrolled

and that Daughter had been absent from school without excuse for either 30 or more

hours in a week or 42 hours in a month.

{¶ 3} After being served with the complaint, on August 25, 2023, Ruggles had

counsel appear on her behalf and file a motion to dismiss the complaint on grounds of -3-

selective prosecution. On September 21, 2023, the trial court overruled Ruggles’s

motion to dismiss.

{¶ 4} On September 27, 2023, Ruggles filed a second motion to dismiss the

complaint in which Ruggles argued, among other things, that the complaint was defective

because it failed to include a written statement of the essential facts constituting the

charged offense as required by Crim.R. 3. On October 23, 2023, the trial court issued a

decision overruling Ruggles’s second motion to dismiss. Although the trial court

overruled the motion, it found that the time period of the conduct alleged under Count

One of the complaint, i.e., September 15, 2022, through December 8, 2022, partially

overlapped with conduct alleged in a separate case against Ruggles that had been

dismissed with prejudice. As a result, the trial court narrowed the time period alleged in

Count One to November 18, 2022, through December 8, 2022.

{¶ 5} Ruggles’s case thereafter proceeded to a two-day jury trial. During trial, the

State presented testimony from the Greene County Juvenile Court diversion counselor

who was assigned to Ruggles’s case. The State also presented testimony from various

school officials and staff members, including the attendance officer of Fairborn City

Schools, the assistant principal at Fairborn High School, the attendance and main-office

secretaries at Fairborn High School, and Daughter’s history teacher. In her defense,

Ruggles presented testimony from two Fairborn police officers who had assisted her with

Daughter. Ruggles also presented testimony from her husband, Claudio; her long-time

friend, Jamie; her teenage niece that lived with her and went to school with Daughter; and

Daughter. The following is a summary of the relevant information that was presented at -4-

trial.

{¶ 6} In January 2022, Ruggles enrolled Daughter, who was then 14 years old, at

Fairborn High School when Daughter was in the ninth grade. On May 20, 2022, the

attendance officer of Fairborn City Schools sent Ruggles a “Habitually Truant Notice”

advising her that Daughter had been absent from school without legitimate excuse for

either 30 or more consecutive hours, 42 or more hours in one school month, or 72 hours

during the school year. State’s Exhibit 1, p. 94. There is no dispute that if a student

meets any of the foregoing criteria, the student is considered a “habitual truant” pursuant

to R.C. 2151.011(B)(18).

{¶ 7} The “Habitually Truant Notice” stated that, because Daughter had met the

threshold for becoming a habitual truant within 21 school days prior to the last day of the

2021-2022 school year, the school was going to schedule an absence intervention

meeting to occur sometime after the start of the 2022-2023 school year. The notice

requested that Ruggles participate in the meeting and advised that the meeting would

involve discussing Daughter’s attendance with a school official and forming an absence

intervention plan. The notice further advised that if the interventions were unsuccessful,

or if more unexcused absences were accumulated after implementing the plan, the school

would have to file a complaint with the Greene County Juvenile Court.

{¶ 8} On August 24, 2023, Ruggles attended an absence intervention meeting with

Fairborn High School’s assistant principal and guidance counselor. Ruggles attended

the meeting via an online video conference call service known as Google Meet. During

the meeting, Ruggles indicated that Daughter’s absences were due to the loss of her -5-

grandmother, hospital visits, missing the bus, and adjusting to a new school and

schedule. After discussing the reasons for Daughter’s absences, the parties developed

an absence intervention plan. The plan included Daughter attending school daily and

communicating and reporting absences to the school. The plan also consisted of the

school monitoring Daughter’s attendance as well as providing any support and/or

resources needed to help Daughter maintain good attendance. State’s Exhibit 1, p. 102.

{¶ 9} Although the absence intervention plan went into effect on September 6,

2022, Daughter’s attendance did not improve. The State presented records establishing

that the school sent Ruggles several written notices of excessive absences and habitual

truancy pertaining to Daughter throughout the 2022-2023 school year. Specifically, the

school sent notices of excessive absences to Ruggles on October 31, 2022; November

8, 2022; February 16, 2023; March 23, 2023; April 14, 2023; and May 16, 2023. State’s

Exhibit 1, p. 123-129. In addition, the school sent notices of habitual truancy to Ruggles

on November 21, 2022; February 16, 2023; March 23, 2023; April 10, 2023; April 18,

2023; May 23, 2023; and May 25, 2023. Id.

{¶ 10} The records presented by the State also established that the school tried to

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